Contents

Introduction

Positions on Article 1 (Persons Covered) and its Commentary

Positions on Article 2 (Taxes Covered) and its Commentary

Positions on Article 3 (General Definitions) and its Commentary

Positions on Article 4 (Resident) and its Commentary

Positions on Article 5 (Permanent Establishment) and its Commentary

Positions on Article 6 (Income from Immovable Property) and its Commentary

Positions on Article 7 (Business Profits) and its Commentary

1. Annex – Positions on the Previous Version of Article 7 and its Commentary

Positions on Article 8 (International Shipping and Air Transport) and its Commentary

Positions on Article 9 (Associated Enterprises) and its Commentary

Positions on Article 10 (Dividends) and its Commentary

Positions on Article 11 (Interest) and its Commentary

Positions on Article 12 (Royalties) and its Commentary

Positions on Article 13 (Capital Gains) and its Commentary

Positions on Article 14 (Independent Personal Services) and its Commentary

Positions on Article 15 (Income from Employment) and its Commentary

Positions on Article 16 (Directors' Fees) and its Commentary

Positions on Article 17 (Entertainers and Sportspersons) and its Commentary

Positions on Article 18 (Pensions) and its Commentary

Positions on Article 19 (Government Service) and its Commentary

Positions on Article 20 (Students) and its Commentary

Positions on Article 21 (Other Income) and its Commentary

Positions on Article 22 (Capital) and its Commentary

Positions on Articles 23 A and 23 B (Exemption Method and Credit Method) and its Commentary

Positions on Article 24 (Non-Discrimination) and its Commentary

Positions on Article 25 (Mutual Agreement Procedure) and its Commentary

Positions on Article 26 (Exchange of Information) and its Commentary

Positions on Article 28 (Members of Diplomatic Missions and Consular Posts) and its Commentary

Positions on Article 29 (Entitlement to Benefits) and its Commentary

Positions on Article 30 (Territorial Extension) and its Commentary